Complaint alleges if AEG Live had fulfilled its promises 'Michael Jackson would not have died on June 25th'

Los Angeles, California (CNN) -- When the Los Angeles County Coroner ruled Michael Jackson's death a homicide, as a result of "acute propofol intoxication" with other sedatives, the coroner's office also cited a lack of recommended equipment for patient monitoring, precision dosing and resuscitation equipment that may have contributed.

Six months later, Dr. Conrad Murray, who administered Propofol to Jackson, was charged with involuntary manslaughter.

But in a recent complaint filed with the Medical Board of California, Jackson's father, Joe Jackson accuses concert promoter AEG Live of neglecting to provide the recommended equipment and a nurse who was supposed to assist Dr. Murray. Those measures could have prevented the singer's death or revived Jackson when he stopped breathing, according to the complaint.

The California Medical Board is responsible for investigating complaints against physicians.

According to a copy of the 169-page complaint, obtained by CNN and verified by Joe Jackson's attorney, Brian Oxman, AEG, over a six week period, allegedly engaged in "unlawful practice of corporate medicine," by hiring, directing, controlling and demanding that Murray medicate Michael Jackson as he prepared for his "This is it" tour in London.

AEG spokesman Michael Roth declined to comment on the complaint, telling CNN that his legal department has not viewed the documents. Joe Jackson was unavailable, according to attorney Oxman.

Murray's civil attorney, Charles Peckham, declined to comment about the specific allegations against AEG after the complaint was filed.

According to the complaint, AEG Live executives were so concerned over Michael Jackson's alleged failure to show up for rehearsals, that AEG representatives demanded that Murray step in and "wean" Jackson off his alleged dependence on medications provided by other doctors which caused chronic fatigue and disorientation. The complaint states that AEG made an "oral agreement" with Murray on May 8, 2009 based on a drafted contract agreement, promising to provide Murray with equipment, supplies and personnel. The complaint states that Murray immediately accepted AEG's offer for a monthly physician's fee of $150,000.

According to the complaint, Murray made his first order of Propofol on May 12, 2009, and stated in a purported e-mail to AEG that he had begun treating the singer as part of their "oral agreement."

On May 28, Murray allegedly grew impatient because he had not been paid by mid-month as promised by AEG, according to the complaint. Before treating Jackson, Murray, a full time cardiologist, had been mired in such heavy debt, that AEG exploited his hardship as a tactic to exert control over his medical decisions, the complaint alleges. More than two weeks after Murray began treating the singer, AEG had not provided Murray with CPR equipment as he requested and never instructed Murray to cease treating Jackson, the complaint states.

In an interview with CNN's Don Lemon, before the complaint was filed, AEG Live Executive Randy Phillips said Dr. Murray was never officially employed by AEG because the contract was never signed. Phillips said the decision to hire Dr. Murray was solely Jacksons and that he demanded it.

"He (Michael) said, 'You don't understand, my body is what fuels this entire venture and like Barack Obama, I need my own physician with me twenty-four-seven. That's not negotiable," Phillips told CNN's Don Lemon. "And he was so strong about it that I just backed off and said, 'This is a battle I can't win," said Phillips.

By June 18, according to the complaint, Jackson had attended only a few rehearsals, prompting AEG Live's Phillips and "This is It" director Kenny Ortega to demand a face to face meeting with him at Jackson's Holmby Hills estate. Phillips and Ortega insisted that Jackson show up for rehearsals or AEG would "pull the plug" on Jackson's rented house and terminate the services of Murray if he missed another rehearsal, the complaint alleges.

On that same evening, Murray allegedly gave Jackson Valium, Ativan, Versed, and Propofol in order to induce sleep, similar to the medications he allegedly administered over the previous five weeks, the complaint alleges. Murray continued this practice without CPR or nursing assistance which AEG had promised, according to the complaint. Jackson rehearsed on June 19, 23 and 24, according to attorney Oxman. Most of the documentary "This is it" was filmed on those dates, according to AEG Live executive Randy Phillips.

On June 24, AEG sent Murray a revised contract agreement, which mirrored the original May 8, 2009, oral agreement, except it required Jackson's signature, the complaint alleges. Murray signed the agreement and faxed it to AEG although the complaint alleges that AEG knew of the inherent dangers of the treatments Murray was administering and "recklessly" withheld life saving equipment that AEG knew was essential to protect Michael Jackson's life.

"Had AEG not violated California law and fulfilled its promise to provide Cardio-Pulmonary Resuscitation equipment and a nurse, Michael Jackson would not have died on June 25th," the complaint alleges.

The complaint is supported by 16 exhibits including a purported cost estimate of Murray's medical services and a copy of the purported contract between AEG and Murray.

The cost of medical equipment and other supplies requested by Murray purportedly totaled $8,000 per month. A nurse was estimated to cost $7,000 per month, according to the complaint. The cost of Murray's rental property in London is said to have totaled $8,000 per month, the complaint stated. Murray, who pleaded not guilty to involuntary manslaughter charges, told LAPD investigators that he was never paid for his treatment of Jackson.

A representative at the California Medical Board confirmed to CNN the filing of Jackson's complaint but declined further comment.